Welcome and thanks for attending today’s webinar, "How Do I Get There From Here?

Demystifying Environmental Compliance."

I'm Bob McIlvaine, Founder and President of The McIlvaine Company. I'll be
moderating the webinar on behalf of Neundorfer, Inc., experts in helping utilities and
industrial companies develop pollution control and energy efficiency strategies.

Neundorfer has also invited experts from several business partners to participate.

At this point, I’d like to ask everyone dialed in to please mute your phones to avoid
picking up any background sounds.

I'd like to start by introducing the five experts who will be talking about
environmental compliance, and give you a brief overview of what we'll be covering
during this one-hour webinar.

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The webinar starts with an overview of the holistic approach to regulatory
compliance.

First, Mike Neundorfer, owner and CEO of Neundorfer, will explain what the holistic
approach is and how it’s used to make confident decisions based on analysis of
critical uncertainties and predetermined factors.

Next, Jeremy Timmons, Chemical Engineer at Neundorfer, will talk about techniques
for successful goal assessment.

Then, wrapping up the first section of this webinar, Marlin Anderson, Senior
Environmental Consultant at Neundorfer, will share insights about the importance of
baseline analysis.

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The second section of today’s webinar focuses on aspects of regulatory compliance
you’ll need to consider when applying the holistic approach.

First, Jeremy Timmons from Neundorfer will talk about fuel selection.

Next, Stephen Storm, Director of Business Development & Technology Advancement

at Paragon Airheater Technologies, will discuss factors involved in fuel preparation
and the combustion process.

Then, John Cavote, Chairman of the Board at United Dynamics Corporation, will talk
about heat transfer.

Next, Marlin Anderson from Neundorfer will discuss compliance considerations

related to environmental control equipment on the back end.

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Tying all this together, Mike Neundorfer will review the holistic approach and why
taking a big picture, systems view results in high-performing, low-cost, flexible
possibilities.

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Finally, we'll wrap up the webinar with a question and answer section. This is your
chance to talk directly with the experts and get your questions answered.

You can submit your questions at any point during the webinar by using the chat
feature. Select “Answers” from the list of participants and send in your comments or
question.
[ Demo ] Or, ask your question directly during the Q&A by un-muting your phone.

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I appreciate everyone’s participation this morning both those presenting and those
listening.

We intend to respect your time by ending on time and by sharing information that
will be useful to you.

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What we don’t know is… <CLICK>

•What details will be included in the new regulations? <CLICK>

•What will be deadline for complying with new regulations?

So the question is: how can we add value when we don’t know what the new regulations will entail
and when they’ll take effect?

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What we do know is… <CLICK>

•New regulations are coming <CLICK>

•New regulations will be more aggressive than existing ones, specifying limits for multiple pollutants
<CLICK>
•Timeframe for compliance will be 3-5 years from enactment

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This morning we will discuss… <CLICK>
process <CLICK>
planning <CLICK>
and connected systems …….not specific solutions.

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1. Resist the rush to find a quick, simple solution <CLICK>

2. If a simple solution exists (unless it is to shut down the process or handily switch to gas firing), it’s
likely more expensive and higher risk than a planned, elegant approach.

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An elegant approach to compliance is based on… <CLICK>

1. Knowledge of baseline operation and emissions <CLICK>

2. Understanding the sensitivities of baseline operation an demission value to changes in equipment
and operating variables <CLICK>
3. Collaborative action to create scenarios that consider all reasonable possibilities, their costs, risks,
and affect on the rest of the system.

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The comprehensive nature of new regulations create opportunities for: <CLICK>

1. Improving thermal efficiency <CLICK>

2. Improving operational efficiency

… as we move to reduce emissions.

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How do we leverage this opportunity? <CLICK>

•Understand, test, measure and model current equipment and process <CLICK>
•Understand options <CLICK>
•Understand sensitivities of…
othermal performance
opollution generation
opollution abatement
… related to current equipment and its operation.

And then…
use the test data to build, link and validate subsystem performance models.

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During this short presentation today, my goal is to provide a brief overview of why
broad based compliance strategies produce the most effective results. (CLICK)

We will also cover some initial phases or techniques that should be considered.
(CLICK)

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Why do broad based (holistic) compliance strategies produce the most effective
results?

We find that a Comprehensive analysis of the goals, constraints and opportunities

that surround any compliance effort produces: (CLICK)

Robust decisions based on a broad spectrum of information (CLICK)

Strategies that are flexible to handle future challenges (CLICK)

with relatively inexpensive contingencies or margins. (CLICK)

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In contrast, we find that single track strategies produce diminishing returns (CLICK)

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We can see in this example how the first level of investment produces the greatest
improvement. (CLICK)

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Equal, subsequent investments produce smaller gains. (CLICK) (CLICK)

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In this example, we predict that a significant effort will be required to achieve a 15%
improvement.

If this improvement level coincides with a target or limit that must be achieved, it is
reasonable to invest more in order to provide margin. (CLICK)

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In this case, however, a 33% increase in investment will be required to produce a
small margin. (CLICK)

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With holistic evaluations, however, we find that strategies that involve multiple,
complementary tracks can be executed to produce more effective results. (CLICK)
(CLICK)

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In this example, executing 3 different improvement tracks to lesser degrees allows us
to achieve the same 15% combined improvement at a much lower level of
investment.

Furthermore,, contingency plans, margin and flexibility for future challenges are less
expensive because we are on steeper segments of each curve.

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When we combine the 3 separate improvement tracks into a single investment versus
improvement relationship we find that the multi-track strategy is superior to a single
track approach. (CLICK)

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The question is: How do we begin the process of developing these improvement
tracks and determining which ones to invest in and to what degree. (CLICK)

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We have found that the initial steps for any improvement effort are the most critical.

This is where individuals and teams have the most influence on the future direction
of a project.

The important steps involve:

Focusing attention on the situation (CLICK)

Discovering possibilities (CLICK)

and creating forward movement (CLICK)

We execute these steps using process of Strategic Inquiry.

Strategic Inquiry is a process in which we first identify the key questions surrounding
the activity.

We then prioritize their importance, decide which ones to examine first and to what
degree. (CLICK)

Involvement of a diverse group of people is important because we want to get a

broad perspective of input in these initial steps so that we are comprehensive in our 29
The first step is to focus everyone's attention on the situation.

We use questions such as these to extract valuable information from the team and
provide a foundation for the effort.

A question a simple as “What are we try to do?”, when asked to a

diverse group of individuals will produce a set of unique and valuable responses.

As the individual views are captured, a shared, broad, understanding of the situation
emerges. (CLICK)

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Step 2 involves the discovery and examination of the possibilities

The goal of this step is to generate a comprehensive list of possibilities to for future
exploration.

This is also a good conversation to have with a diverse group.

Many times maintenance people or performance engineers have projects in process

that would also benefit a compliance effort.

Anything that improves combustion performance or unit efficiency will generally

help. (CLICK)

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Finally, it is critical to create momentum.

Which questions are the most important to investigate?

This goal of this step is to provide focus and produce action. (CLICK)

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OK, so what is the value of starting a compliance journey in this manner? (CLICK)

We believe that the process facilitates alignment of all stakeholders with goals, scope
and constraints of the compliance effort. (CLICK)

The process also eliminates paralysis by creating positive momentum, action plans
and the framework for contingencies. (CLICK)

For any improvement effort, establishing a set of comprehensive metrics with

proper measurement and evaluation methods is a crucial step. Dr. Marlin Anderson
will now discuss these issues in more detail. (CLICK)

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1.This process starts with the generation of linked baseline data. We are used to doing
emission testing that focuses on the stack measurements and, if we are lucky, the test
records include some fuel and maybe some rudimentary boiler operating data.

2.The stack test data we have relied on in the past needs to be expanded to include every
aspect of the system at the time of test including things like fuel analysis, fuel preparation,
combustion parameters, ash LOI, and operating data with condition of the boiler and
downstream equipment.

3.The data needs to be linked in time to provide input and validation for performance
models.

4.Performance models are then used for scenario development.

5.Scenarios are evaluated for cost and risk and the lowest risk and cost compliance scenario
is implemented.

6.This whole process takes a new approach of well planned, and facilitated meetings with
people with responsibilities ranging from fuel purchase to operations, maintenance, and back
end equipment responsibility.

7.It is especially difficult to hold back from the rush to solution while the plan for generating
linked baseline data is executed and scenarios are discusses and evaluated.

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Key Points
• Any Approach to Combustion, Boiler Efficiency and Environmental performance
should encompass a holistic approach.
• This approach should evaluate the entire system evaluation including the
condition and performance of the auxiliary equipment for the plant.
• In addition, fuel quality, cycle performance and the firing system together have a
huge impact on a plants overall thermal efficiency and ultimately the
environmental performance of the unit.

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Key Points
• Fuel Selection should also be considered when evaluating plant operations,
reliability, efficiency and environmental impact.
• With solid fuel firing, a small change in the sulfur and iron in the fuel ash can have
a significant impact on boiler reliability especially with staging combustion for
NOX control.
• Considering that Ash chemistry and slag propensity are also influenced by the %
of ash and/or the problematic mineral ash constituents, these must be taken into
consideration when determining a plants operational parameters.
• Other variables such as Hydrogen and moisture can also have a significant impact
on the efficiency, flue gas volume and heating value of the fuels.
• On a pulverized coal unit, particle sizing and quality which can easily enhance or
decrease lower furnace heat absorption which is vital to heat exchange process of
the cycle.
• From an environmental stand-point, the Nitrogen, Sulfur, Carbon to Volatile
Ratios, Ash quantity, Resistivity, Ammonia slip, dew-point, etc. - - all can have a
major influence on environmental performance output as well as Long Term
Reliability of the Entire System.

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Key Points
• As discussed in the previous slide, it was noted that the quality of the fuel can
have an impact of the Ash chemistry..
• In our industry today, the common usage of chemical injection and sorbents
upstream or downstream of the airheater can lead to major challenges which
can exacerbate performance issues even further.
• For example, the conversion of the sulfur oxides to SO3 has a tremendous impact
on the acid dew-point of the combustion flue gas and can results with plugging
and/or corrosion of the airheater.
• In addition, slagging and fouling within the boiler can lead to flue gas
stratifications impacting a units heat transfer as well as plugging of and SCR, ABS
deposition at the airheater, ductwork or perforated plates which were intended
to distribute even flow profiles of flue gas to the particulate collection equipment.

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Key Points
• If the airheater becomes chocked or overwhelmed with air in-leakage from the
boiler, this c an impact the dynamics of the entire system and/or limit the output.

• Obviously this illustration is not drawn to scale. However, its intent is to relate
the airheater as being the intermediary between the boiler and the air pollution
control equipment.

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Key Points
• The Airheater is the final heat exchanger on the unit. Its important to consider
the airheater as the heart (or lungs) of the air & gas management system.

• The Airheater supplies hot pre-heated combustion air to the burners.

• On a Pulverized Coal Fired Unit, the air heater supplies Hot air to the mills
assisting with pulverization as well as fuel transport energy and enhancing mill
capacity on higher moisture, lower BTU fuels by improving coal fineness.

• Improved air supply and coal fineness to the unit yields improved Combustion,
flame stability, LOI, Efficiency and Reliability. Furthermore, maximum heat
recovery and reliability is important to ensure thermal efficiency, temperature
control and flue gas volume to the air pollution control equipment.

• Over the past several years, Paragon has evolved and is providing rugged and
proven performance solutions for the refurbishment of regenerative airheaters.

• Minimizing the air “leak-by” from the air to gas sections and utilization of the
proper materials, element design and critical tolerances are vital for ensuring
thermal and environmental performance.

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Key Points

• As compared with the boiler components, a typical regenerative airheater has a

significant amount of heating surface in a small area.
• Each 30-40 degrees of temperature at the airheater outlet can influence the
efficiency by ~1% and again, making the airheater typically responsible for more
than 10% of a units overall thermal efficiency.
• However, thermal efficiency is only the beginning.
• If a boiler has a significant amount of air in-leakage and/or air leakage at the
airheater, this impacts the combustion process, particulate sizing, concentrations
of carbonaceous ash and also velocity distribution an corrosion and erosion
through the heating elements of the airheater itself.
• After the airheater, a secondary effect is the corresponding high velocities and
pressure differentials through the precipitator..

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Key Points
• Just to illustrate an example of a Holistic Evaluation and approach to unit
performance, in a recent “best practices” demonstration completed in Asia, I was
directly involved with a project where the opportunities at the boiler, turbine and
operational performance improvements could reduce CO2 emissions in the
magnitude of 124,000 metric tons annually for one 200 MW unit alone.
• Many of the improvements made during the program were considered “low
hanging fruit” and ultimately resulted in not only improved emissions, but also
fuel savings making a holistic approach to performance evaluation a Win for
everyone.

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After creating reliable subsystem performance models, we can use them to
understand options for changing proactive and then reactive elements of the plant
system and begin to input risk and cost into the models.

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Thanks, Mike. We now open the webinar up to your questions. Here’s a review of
how to submit questions using the chat feature. You may also now un-mute your
phone and ask a question directly.

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Thanks everyone for your participation and some great discussion. If you asked a
question that didn’t get answered, we will be get back to you soon to continue the
conversation. In the meantime, Neundorfer's online Air Pollution Control Compliance
web page is a great resource to learn more about environmental compliance.

The entire webinar is being archived and will be available within the next couple days
on Neundorfer’s Compliance web page.

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Here is contact information for the experts who presented information during the
webinar, so you can get in touch to learn more. Jeremy, Stephen, John, Mike and
Marlin welcome your calls and e-mails.

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We're planning another Neundorfer-sponsored webinar soon to build on what was
discussed today. The second webinar, "The Time to Start is Now! Connecting
Operating Data with Compliance Results," will have a date set soon, and we'll let you
all know more details then.

Also, next week Neundorfer and its holistic approach business partners are hosting a
special learning event in Willoughby, Ohio. The MACT Scenario Planning Workshop is
an opportunity to share ideas with your peers and gain insights about how to address
critical uncertainties surrounding air pollution control regulatory changes. We hope to
see you there.

Thanks everybody, and have a great day!

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